The Environmental Protection Network Analysis of Trump Administration Proposals for FY2018 Budget for the Environmental Protection Agency March 22, 2017 Executive Summary President Trump’s Budget Blueprint takes an ax to EPA, threatening severe damage to health and environmental programs that have protected Americans for decades. State agency funding is also slashed, even though the Trump Administration is proposing to simultaneously shift more responsibility to the states. The budget further calls for elimination of most EPA climate programs even as the earth continues to warm and climate change impacts grow worse. There is no evidence that the cuts are based on any real analysis of changing needs. Steep cuts and elimination of many EPA programs seem to reflect ideological views about the role and value of government programs that protect public health and the environment. The Trump Budget Blueprint for EPA appears to be nothing less than a full-throttle attack on the principle underlying all U.S. environmental laws – that protecting the health and environment of all Americans is a national priority. Introduction The following budget analysis is provided by the Environmental Protection Network, a group of former employees of EPA and other federal and state agencies who have come together to help policy makers and the public better understand the nature and implications of Trump Administration proposals. Having worked for both Republican and Democratic Administrations over the years, we are fully aware that environmental issues can be complex and that there can be legitimate differences of opinion, including about the value of a program or the appropriate overall level of EPA funding. We do not approach our analysis of the Trump Administration’s budget proposal with the view that every program must continue as it exists today and that no priority can be reconsidered. However, we do believe that the immense and ill-conceived cuts that the Trump Administration has proposed would inflict severe harm to the system of environmental protection that the nation has built over the past half century. The unavoidable consequences of the cuts would be more pollution that causes illness, death and dangerous changes to the earth’s climate and ecosystems on which Americans and people around the world depend. Of all the large federal agencies targeted for cuts by the Trump Administration, EPA is hardest hit. After a decade of mostly flat or declining budgets, EPA is being handed cuts of 31% to its budget and 21% to its workforce. Clearly, the President is trying to keep his promise of reducing EPA to “little tidbits.”1 The backdrop to the proposed cuts is the quiet underfunding of EPA and many state and local environmental agencies that has taken place for years. A strong argument can be made that, although some programs may warrant review, others badly need new investment simply to carry out the missions that Congress gave EPA. Added resources are also needed to tackle newly recognized environmental 1 https://www.washingtonpost.com/news/energy-environment/wp/2017/03/16/trumps-scorched- earth-epa-budget-draws-swift-reactions/?utm_term=.fb83f89e9cab Environmental Protection Network -- March 22, 2017 problems. The budget proposal does not even support the “essential” clean air and water mission that the Trump Administration has identified.2 It cuts EPA funding for those essential programs and cuts nearly in half the grants that support state agencies, which are central to implementing these programs and ensuring environmental results on the ground. In the following budget analysis, we summarize key elements of the proposed budget and its implications, including the history of past appropriations and its impacts on the partnership between EPA and States. We then discuss in more detail the impacts the budget would have on many specific EPA programs. We consider our analysis to be a work-in-progress that will be updated as additional information and insights become available and future developments in the budget process occur. Contents I. Summary of the Proposed FY2018 EPA Budget II. EPA’s Budget Is Already Historically Low III. State Environmental Agencies and the EPA-State Partnership Crippled IV. Climate Protection Programs Eliminated V. Clean Air, Water, and Land Programs Jeopardized VI. Science and Research Funding Cut in Half VII. Programs to Protect America’s Greatest Water Bodies Zeroed Out VIII. Programs for Vulnerable Communities Targeted for Elimination IX. Enforcement Cut at Cost of More Pollution and Less Accountability Appendix: Partial List of Programs Proposed for Elimination 2 The Washington Post, “Trump Nominates Scott Pruitt, Oklahoma Attorney General Suing EPA on Climate Change, to head the EPA,” December 8, 2016. https://www.washingtonpost.com/news/energy- environment/wp/2016/12/07/trump-names-scott-pruitt-oklahoma-attorney-general-suing-epa-on- climate-change-to-head-the-epa/?utm_term=.0eb5b7b58f9c 2 Environmental Protection Network -- March 22, 2017 I. Summary of the Proposed FY2018 EPA Budget The Trump Administration’s Budget Blueprint for the 2018 fiscal year would cut EPA’s budget by 31% and its workforce by 21%. Overall, EPA’s budget would be cut from $8.2 billion to $5.7 billion,3 returning EPA to inflation-adjusted funding levels not seen since the 1970s4, before Congress significantly expanded the agency’s mission by enacting or strengthening environmental laws like the Clean Air Act, the Clean Water Act, the Resource Conservation and Recovery Act, the Superfund hazardous waste cleanup law, the Safe Drinking Water Act, the Oil Pollution Act, and, just last year, the Toxic Substances Control Act. The Budget Blueprint’s proposal to cut EPA’s workforce by 3,200, from 15,376 to 12,176, or by 21%, in one year would drastically undermine the agency’s ability to implement these and other statutes. Cutting EPA’s workforce by such a large percentage in one year would be unprecedented in the 47-year history of the agency. For perspective, the Blueprint’s “savings” of $2.6 billion from EPA’s current budget of $8.2 billion is a tiny fraction of the Trump Administration’s overall proposed $1.15 trillion budget for discretionary spending. Reducing EPA’s budget by $2.6 billion would save Americans about $9 per person on average, if the Administration returned the money to Americans in the form of lower taxes. The Administration has made clear, however, that the “savings” from cutting EPA’s budget would be used to fund more military spending, so tax bills will not be lowered. Those “savings” would instead come at far higher costs to Americans’ health, property and environment.5 The Budget Blueprint provides few details about how its draconian cuts would be distributed among EPA programs. Where details are lacking, however, more insight into the Administration’s plans for the agency can be found in the earlier OMB “Passback,” an internal document specifying line-by-line cuts and instructions to EPA.6 Many of the budget numbers in the Passback have become public. We have obtained additional information about the Passback, and we have used that information in this report.7 3 More specifically, the Trump Administration’s Budget Blueprint would reduce EPA’s total budget from $8.14 billion in FY2016, and $8.244 billion in FY2017,3 to $5.7 billion. Congress has not yet provided a full-year appropriation for FY2017; the FY2017 figure is the annualized extension of the December 2016 continuing resolution (CR) that provided funding through April 2017 (but excludes one-time, non- continuing changes made in the CR). 4 See Section II. 5 Many investments in environmental protection pay huge dividends for the nation. For example, a 2011 peer-reviewed EPA study mandated by Congress estimates that pollution reductions from the Clean Air Act Amendments of 1990 – a single environmental law – will avoid 230,000 premature deaths and produce total benefits valued at $2 trillion in 2020. This central estimate exceeds costs by more than 30-to-1. See The Benefits and Costs of the Clean Air Act from 1990 to 2020, U.S. Environmental Protection Agency Office of Air and Radiation, March 2011 available at https://www.epa.gov/sites/production/files/2015-07/documents/summaryreport.pdf 6 Readers may notice that this report compares FY2018 figures to FY2017 annualized continuing resolution levels for the Blueprint, but to FY2016 enacted levels for the Passback. The FY2016 and annualized FY2017 CR levels are close but not identical. The Blueprint itself makes comparisons using FY2017, so this report uses that information. For the Passback, which has much more line-by-line detail, FY2016 enacted figures are used because of availability of line-by-line detail for FY2016 enacted figures. 7 Many numbers in the Passback have been reported by numerous media outlets. The additional numbers used in this analysis were obtained from S. William Becker, Executive Director of the National 3 Environmental Protection Network -- March 22, 2017 In considering the Passback’s specific cuts, however, it is important to bear in mind that those cuts are likely to understate many of the cuts underlying the Budget Blueprint, since the Blueprint calls for even deeper overall cuts than the Passback (31% versus 25% cut in EPA’s budget).8 But while the size of specific cuts may be in flux, the overall direction and purpose of the Administration’s budget proposals are clear – to cripple the ability of EPA and states to deliver on congressionally mandated missions for protecting Americans’ health and environment. Impacts on EPA programs Following are key observations from our analysis of the Budget Blueprint and Passback to date. Many of these points are further explained in separate sections of this analysis. As noted above, our analysis will be updated as further information becomes available and as the budget process proceeds.